May 28, 2008

MEMORANDUM

TO:	Cyndy Merse

CC:		Kristina Meson, Eileen Naples, and Rhonda Minnick

FROM:	Earl Harris, Boris Rachev and Jennifer Agopsowicz

SUBJECT:	Draft Burden Estimates for Schools Chemical Cleanout Campaign
(SC3) Survey; Work Assignment No. 1-50, Contract No. EP-W-07-003

Attached is a document that estimates the annual burden of the SC3
Survey.  It is submitted under Task 3 of the work assignment referenced
above.  Please do not hesitate to contact us with questions or comments.

Draft Burden Estimates for Draft Survey Form to be used under Schools
Chemical Cleanout Campaign (SC3)

1.0	Introduction

The U.S. Environmental Protection Agency (EPA) is developing a survey to
collect information from its Partners under the Schools Chemical
Cleanout Campaign (SC3).  Before the survey can be distributed to 10 or
more organizations, EPA must obtain clearance from the U.S. Office of
Management and Budget (OMB) pursuant to the 1995 Paperwork Reduction Act
(PRA).  To request OMB clearance, EPA must submit an Information
Collection Request (ICR) that describes and justifies the proposed
survey and estimates the annual hour and cost burden to respondents
(i.e., Partners) and the Agency.

This document presents EPA’s draft burden estimates for respondents
and the Agency to carry out the survey.  Section 2.0 of this document
briefly describes the SC3 Program and draft survey instrument.  Section
3.0 presents EPA’s draft burden estimates.  

Over the coming months, EPA will continue to refine its survey and
burden estimates as it prepares the ICR.  Among other things, EPA will
conduct a pre-test of the survey.  EPA will ask participants of the
pre-test for feedback on the survey (e.g., its clarity and
effectiveness) and their burden to complete it.  In addition, EPA will
review the public’s comments received in response to the notice in the
Federal Register announcing its intent to forward an ICR to OMB.  EPA
will modify the survey and ICR to reflect this feedback as appropriate
before forwarding them to OMB.

2.0	Background of SC3 and Proposed Survey

The Schools Chemical Cleanout Campaign (SC3) was created in 2004,
building on regional, state, tribal, and local SC3 programs across the
nation.  The National SC3 program was launched in March of 2007.  The
National SC3 program uses a variety of innovative approaches to achieve
three goals: (1) removal of outdated and dangerous chemicals from K-12
schools; (2) prevention of future accumulations of chemicals and
reduction of accidents by establishing prevention activities such as
good purchasing and management practices; and, (3) raising national
awareness of the problem.  

One of the ways that EPA accomplishes its goals is by partnering with
organizations that volunteer to assist schools in the management of the
schools’ chemicals and the removal of schools’ chemical waste. 
There are currently eleven Partners.

To evaluate the current state of the program and determine what the
future direction should be, EPA intends to conduct a voluntary survey of
its Partners to gather information on their activities and the results
of their work under the program.  To this end, EPA has prepared a draft
survey form with four main goals: 

Collect general information about the Partners (e.g., reasons for
joining the SC3 Program, future plans, etc.);

Identify the accomplishments of Partners under the SC3 Program and how
many schools/school districts, students and school personnel are
involved/impacted;

Identify additional resources needed by Partners to accomplish SC3
goals; and

Collect lessons learned from Partners on what has worked and what has
not worked under the Program, so this information can be shared with
others.

EPA intends to ask Partners to complete and submit the survey while the
partnership is in effect.  The survey will be available to Partners in
an electronic format.  They can submit completed surveys by email,
postal mail, or fax. 

3.0	Hour and Cost Burden of the Collection

This section describes EPA’s burden estimates for respondents and the
Agency to carry out the survey.  Sections 3.1 and 3.2 describe the
Agency’s assumptions used in calculating the annual bottom-line burden
to respondents and Agency, respectively.  Section 3.3 presents the
estimated bottom-line annual burden to respondents and the Agency. 

	3.1	Respondent Burden Assumptions                                      
                           

The following paragraphs describe the assumptions used to derive the
annual respondent burden estimates.  Exhibit 1, presented in Section
3.3, provides an estimate of the bottom-line annual burden to
respondents under the survey.  

Respondent Universe and Burden Hour Assumptions

There are currently eleven Partners in the SC3 Program.  In addition,
EPA expects that eleven new Partners will join SC3 each year.  Each
Partner will be asked to complete and submit the survey annually.

EPA estimates that it will take a Partner one hour, on average, to
complete and submit a survey for the first time.  EPA estimates that a
Partner will take less time to complete and submit a survey in each
subsequent year.  This is because these Partners will be able to build
from their previously submitted survey.  For example, some of the
survey’s questions ask a Partner to provide general information about
its organization (e.g., how it became aware of SC3, why it joined SC3,
etc.).  Partners would not need to provide new responses to such
questions if their previous responses are still valid.  In addition,
they will be more familiar with the instructions and information needs
than the first time.  Because of these reasons, EPA estimates that it
will take a Partner 45 minutes, on average, to update and submit a
survey in each subsequent year.

The table below shows the number of Partners expected to complete the
survey in each of the three years of the ICR.  It shows that:

In the first year of the ICR, EPA estimates that the eleven existing
Partners, as well as the eleven new Partners expected to join the
Program during the year, will complete the survey for their first time. 


In the second year, EPA estimates that the 22 existing Partners will
update their previously completed survey.  In addition, eleven new
Partners will complete the survey for their first time.

In the third year, EPA estimates that the 33 existing Partners will
update their previously completed survey.  In addition, eleven new
Partners will complete the survey for their first time.

Based on these assumptions, the table shows the average annual number of
Partners estimated to complete the survey during the three-year life of
this ICR (i.e., the total number of Partners divided by three years). 
Specifically, it shows that, on average each year, 15 Partners will
prepare a survey for their first time and 18 Partners will update a
survey that had been completed in a previous year.  

Partners	Annual Number of Partners	Average Annual

Number of Partners*

	Year 1	Year 2	Year 3

	Partners that complete survey for the first time	22	11	11	15

Partners that update survey that had been completed in a previous year	0
22	33	18

Total	22	33	44	33

* Total number of Partners in Years 1-3 divided by three years (includes
rounding).

EPA used the average annual number of respondents, along with the burden
estimates described above, to estimate the average annual burden to
respondents.  Specifically, EPA estimates that 15 Partners will take one
hour to prepare a survey for the first time and 18 Partners will take 45
minutes to update their survey on average each year.  These assumptions
are reflected in Exhibit 1. 

Respondent Cost Assumptions

Exhibit 1 reflects the following cost assumptions:      

Labor costs – The respondent labor costs in Exhibit 1 were obtained
from the “May 2006 National Occupational Employment and Wage
Estimates.” The estimates can be found in the Occupational Employment
Statistics, U.S. Department of Labor, U.S. Bureau of Labor Statistics. 
EPA updated the 2006 wage estimates to 2008 wage levels using the
employment cost index.  EPA then multiplied the rates by the labor cost
fringe benefits and overhead factor of 1.4845.  Based on this, EPA
estimates an average loaded respondent hourly labor rate of $64.63 for
legal staff, $69.61 for managerial staff, $45.44 for technical staff,
and $22.99 for clerical staff.

Operation and maintenance (O&M) costs – O&M costs are defined by the
PRA as the recurring costs associated with a collection of information
(e.g., postage, photocopying, etc.).  EPA expects all Partners to use
their existing email capabilities to submit completed surveys to EPA. 
EPA does not expect any O&M costs to respondents in carrying out the
survey.

Capital costs – Capital costs usually include any produced physical
good needed to provide the needed information, such as machinery,
computers, and other equipment.  EPA does not expect any capital costs
to respondents in completing the survey.

3.2	Agency Burden Assumptions

The following paragraphs describe the assumptions used to derive the
annual Agency burden estimates.  Exhibit 2, presented in Section 3.3,
provides an estimate of the bottom-line annual burden to the Agency
under the survey.  

Agency Burden Hour Assumptions

EPA estimates that Agency personnel will take 15 minutes on average to
review and keep records of each completed survey collected from
Partners.  This is reflected in Exhibit 2.

Agency Cost Assumptions

Exhibit 2 reflects the following cost assumptions:      

Labor costs – Unloaded hourly wage rates for EPAs’ activities were
taken from the 2008 General Schedule and Locality Pay Tables from the
U.S. Office of Personnel Management.  EPA then multiplied the rates by
the labor cost fringe benefits and overhead factor of 1.6.  Based on
this, EPA applied the following average loaded hourly wage rates for
government labor: $76.67 per hour for legal staff, $70.46 per hour for
managerial staff, $59.63 per hour for technical staff, and $22.82 per
hour for clerical staff.

Operation and maintenance (O&M) costs – EPA does not expect any O&M
costs to the Agency in carrying out the survey. 

Capital costs – EPA does not expect any capital costs to the Agency in
administering the survey.

3.3	Bottom-line Annual Respondent and Agency Burden

Exhibit 1 shows that the bottom-line annual respondent hour and cost
burden is estimated to be 28 hours and $1, 247. 

Exhibit 2 shows that the bottom-line annual Agency hour and cost burden
is estimated to be 8 hours and $388.  



Exhibit 1*                                                              
                                                                        
                                                                        
                                                                        
                                                                        
                        Estimated Annual Respondent Hour and Cost Burden
- SC3 Survey





 	Hours and Costs Per Respondent Activity	Total Hours and Costs

Information Collection Activity	Legal	Managerial 	Technical	Clerical
Labor Hours/Activity	Labor Costs/Activity	Capital Costs	O&M Costs	No. of
Respond./   Activities	Total Hours/Year	Total Cost/Year

	$64.63 	$69.61 	$45.44 	$22.99 







	Survey Instrument

Partners complete survey for the first time	0.00	0.10	0.70	0.20	1.00
$43.37	$0.00	$0.00	15	15	$650.55

Partners update survey that was previously completed	0.00	0.10	0.50	0.15
0.75	$33.13	$0.00	$0.00	18	14	$596.34

Total 	0.00	varies	varies	varies	varies	varies	$0.00	$0.00	33	29
$1,246.89

* Exhibit includes rounding.



Exhibit 2*                                                              
                                                                        
                                                                        
                                                                        
                          Estimated Annual Agency Hour and Cost Burden -
SC3 Survey





 	Hours and Costs Per Agency Activity	Total Hours and Costs

Information Collection Activity	Legal	Managerial 	Technical	Clerical
Labor Hours/ Activity	Labor Costs/ Activity	Capital Costs	O&M Costs	No.
of Agency Activities	Total Hours/ Year	Total Cost/ Year

	$76.67 	$70.46 	$59.63 	$22.82 







	Survey Instrument

Review and keep records of completed surveys 	0.00	0.05	0.10	0.10	0.25
$11.77	$0.00	$0.00	33	8	$388.41

Total 	0.00	0.05	0.10	0.10	0.25	$11.77	$0.00	$0.00	33	8	$388.41

* Exhibit includes rounding.



 An ICR is normally effective for three years from the date of OMB
approval.  After three years, the ICR must be updated and submitted to
OMB for renewal.

 Source: The 1.4845 fringe and overhead multiplier factor represents
36.45% full fringe benefits factor plus 12% overhead cost factor.  For
the 12% overhead estimate see OMB Circular No. A-76, Attachment C, May
29, 2003: Calculating Public-Private Competition Costs, Figure C1 Table
of Standard A-76 Costing Factors.  The document can be found at:   
HYPERLINK
"http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.p
df" 
http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.pd
f .  For the 36.45% fringe benefits estimate see the Update to Civilian
Position Full Fringe Benefit Cost Factor, Federal Pay Raise Assumptions,
Inflation Factors, and Tax Rates used in OMB Circular No. A-76,
“Performance of Commercial Activities," October 31, 2006.  The
document can be found at:
http://www.whitehouse.gov/omb/memoranda/fy2007/m07-02.pdf.

May 21, 2008: Draft Burden Memorandum - Page   PAGE  5 

May 7, 2008: Draft Burden Memorandum - Page   PAGE  1 

May 21, 2008: Draft Burden Memorandum - Page 6

